Are printed products with both FSC-Recycled and FSC-Mix 70% paper covered by the Regulation?
According to Chapter 7(b) of the EUDR Guidelines, printed products made from recycled paper (FSC-Recycled) are not covered by the Regulation? But now the cover of a perfect bound brochure is made of FSC recycled material and the content is made of a printing stock that is declared as FSC Mix 70%. Is the larger quantity of the printing material – i.e. the content paper – taken into account here?
4 Answers
Anonymous User
Hi Johanna
I understand that a certain amount of pre-consumer material has been used in the paper. As a print shop that purchases the FSC Recycled-certified paper from our paper merchant and the paper merchant in turn from the paper mill, we must assume that the material has been correctly declared in the upstream process of the supply chain. We also have no testing equipment in production to check the durability of the substrate – the time window between receipt and dispatch of the goods is sometimes very short, or if the paper is printed, it could only be checked between the time of further processing (finishing) and provision for customs export.
Anonymous User
In your opinion, is it sufficient for a product to be made entirely from FSC Recycled 100% to be exempt from the EUDR? According to a factsheet from FSC, it is. But on the other hand, it cannot be ruled out that pre-consumer material is used in FSC Recycled. This would be material that has not yet gone through the entire life cycle, as stated in the EUDR, in order to be excluded.
Anonymous User
Hello Vincent
I agree with your assessment. The only question is whether I still have to list the FSC recycled content of the printed product in the DDS, as otherwise it is not complete. As far as I know, there is currently no option in TRACES to declare a “non-relevant” product component.
Anonymous User
Hi Matteo. This is my personal understanding. As per the latest FAQ (April 2025), products have to be made ENTIRELY from recycled material to be excluded (see 2.8). This means that a mix would need to undergo due diligence for the non-recycled part.
